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Ruling

2001 Ruling 2001-0096713 - CREDIT UNION SHARES

XXXXXXXXXX shares meet the criteria of "primary capital" as described in XXXXXXXXXX, and will carry the following rights and restrictions: a) The shares will have a par value of $ XXXXXXXXXX per share; b) Any entitlement to dividends will be non-cumulative. ... XXXXXXXXXX shares meet the criteria of "secondary capital" as described in XXXXXXXXXX and will carry the following rights and restrictions: a) The shares will have a par value of $ XXXXXXXXXX per share; b) Any entitlement to dividends will be cumulative with a stated dividend rate established at the time of issuance. ...
Ruling

2001 Ruling 2001-0108873 - LEVERAGED BUY-OUT

., a corporation incorporated under the laws of the state of XXXXXXXXXX; (c) "CBCA" means the Canada Business Corporations Act, as amended; (d) "Targetco" means XXXXXXXXXX, a corporation incorporated under the laws of the Province of XXXXXXXXXX and continued as a federal corporation under the Canada Business Corporations Act, as amended; (e) "Targetco Acquisitionco " means XXXXXXXXXX, an indirect wholly-owned subsidiary of Parentco incorporated on XXXXXXXXXX, under the laws of the province of XXXXXXXXXX; (f) "Targetco Acquisition Debt" means the funds borrowed by Targetco Acquisitionco and used to purchase all of the common shares of Targetco; (g) "Newco" means the wholly-owned subsidiary of Targetco Acquisitionco that will be incorporated under the laws of the Province of XXXXXXXXXX; (h) "Amalco" means the corporation resulting from the amalgamation of Newco and Targetco under the laws of the Province of XXXXXXXXXX; (i) "Offer" means the offer by Parentco, through Targetco Acquisitionco, to purchase by way of a take-over bid all of the issued and outstanding common shares in the capital of Targetco made to Targetco shareholders. ... These rulings are provided subject to the limitations and qualifications set out in Information Circular 70-6R4 issued by the Canada Customs & Revenue Agency on January 29, 2001 and are binding upon the Agency provided that the proposed transactions are completed on or before XXXXXXXXXX. ...
Ruling

2002 Ruling 2001-0112583 - UNFUNDED SUPPLEMENTAL PENSION PLAN

The Employer is a registered charity exempt from tax under paragraph 149(1)(f) of the Income Tax Act (Canada) (the "Act") (registration # XXXXXXXXXX). 4. ... The RPP is a registered pension plan, as defined in subsection 248(1) of the Act, under the Agency registration # XXXXXXXXXX. ...
Ruling

2002 Ruling 2002-0161373 - CREDIT UNION SHARES

The first tranche of XXXXXXXXXX shares met the criteria of "primary capital" as described in XXXXXXXXXX and carry the following rights and restrictions: a) the shares have a par value of $ XXXXXXXXXX per share; b) any entitlement to dividends is non-cumulative and the shares do not have voting rights, except in respect of matters which affect the rights attributable to the XXXXXXXXXX shares; c) the shares are redeemable solely at Xco.'s discretion for an amount equal to the shares' par value, plus any declared, but unpaid dividends. ... The first tranche of XXXXXXXXXX shares met the criteria of "secondary capital" as described in XXXXXXXXXX and carry the following rights and restrictions: a) the shares have a par value of $ XXXXXXXXXX per share; b) any entitlement to dividends is cumulative with a stated dividend rate established at the time of issuance and the shares do not have voting rights, except in respect of matters which affect the rights attributable to the XXXXXXXXXX shares; c) the shares are not redeemable by Xco. or retractable by the member, except in the event of any unforeseen occurrences including, but not necessarily limited to the death of a member or extreme economic hardship in cases where a member properly establishes such a claim. ...
Ruling

1999 Ruling 9922793 - SUPPLEMENTAL EMPLOYEE RETIREMENT PLAN

The Registered Plan provides a lifetime pension equal to, for each year of Credited Service in the plan, (a) XXXXXXXXXX% of their Final Average Earnings (as defined therein) up to the latest three-year average of the Yearly Maximum Pensionable Earnings (YMPE) for purpose of the Canada Pension Plan ("Average YMPE") plus (b) XXXXXXXXXX % of their Final Average Earnings in excess of the latest three-year average of the Average YMPE. 4. ... The University is proposing to implement the SRA which would provide pension benefits in excess of the limits under the Act described in paragraph 4 above, and would have the following attributes: a) The pension benefit payable under the SRA will be calculated as the amount determined under the following formula: benefit payable = A- B where: A is the annual defined benefit pension benefit that would be payable as described in 3 above and, in greater detail, in your letter to us; and B is the annual defined benefit pension benefit payable under 4 above. 6. ...
Ruling

2000 Ruling 2000-0024213 - UNFUNDED RETIREMENT PLAN

The Executive has been employed by the Company since XXXXXXXXXX and has received the following annual salary: Year Annual Salary XXXXXXXXXX $ XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX 4. ... That ruling was binding upon Revenue Canada (now the Canada Customs & Revenue Agency or the "Agency") provided that the supplementary executive retirement plan that was the subject of the ruling was established by XXXXXXXXXX. ...
Ruling

1999 Ruling 9902383 - REORGANIZATION

(d) Holdco 2 will transfer, at fair market value, to Holdco XXXXXXXXXX Class A shares of Holdco 5 and, as sole consideration therefor, Holdco 1 will issue to Holdco XXXXXXXXXX % non-cumulative special preferred shares, Series I, having an aggregate redemption and retraction price equal to the fair market value of the XXXXXXXXXX Class A shares of Holdco 5 being transferred to Holdco 1. ... The aggregate addition to the paid-up capital in respect of the XXXXXXXXXX % special preferred shares of Holdco 1 so issued will not exceed the ACB of the Class A shares of Holdco 5 to Holdco 2 being transferred to Holdco 1. ...
Ruling

1999 Ruling 9909123 - SUPPLEMENTAL PENSION ARRANGEMENT

The Employer applied for and received an advance income tax ruling with respect to a similar plan on XXXXXXXXXX, 1996 (File # 953306-3). ... Subject to the limit described herein, the Participant's notional account will be credited each month with an amount equal to XXXXXXXXXX % of the amount by which the Participant's annual salary exceeds the Annual Limit (which, ignoring compounding, equates to the annual RPP contribution rate of XXXXXXXXXX%) However, no amounts will be credited to the Participant's notional account in respect of the Participant's annual salary that exceeds $XXXXXXXXXX or XXXXXXXXXX of the money purchase limit, within the meaning assigned by 147.1(1) of the Act, for the year, if greater. ...
Ruling

2008 Ruling 2007-0241221R3 - 55(3)(b) butterfly reorganization

H in the principal amount of $XXXXXXXXXX plus interest thereon at the rate of XXXXXXXXXX % per annum. ... A is the controlling shareholder of DC, holding approximately XXXXXXXXXX % of its outstanding shares. ... Each of the preceding shareholders holds approximately XXXXXXXXXX % of the outstanding shares of DC. ...
Ruling

2010 Ruling 2010-0353101R3 - Article IV(7)(b) Restructuring

The common shares of Pubco are listed for trading on the XXXXXXXXXX Stock Exchange under the symbol "XXXXXXXXXX ". 3. ... The rate of interest on Debt 1 and Debt 2 will be equal to the XXXXXXXXXX London Interbank Offered Rate plusXXXXXXXXXX %. 19. ... The rate of interest on the Canco Note will be equal to the XXXXXXXXXX London Interbank Offered Rate plus XXXXXXXXXX %. 25. ...

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